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Lesson 27 of 42 · Part I · Level 2 · Explained

Payment service providers, mobile wallets and the ERQ choice

Freelancers and small online sellers can now be paid through international marketplaces, payment operators abroad and mobile wallets at home. What banks, MFSPs and PSPs must check, the USD 1,000 e-commerce rule, QR-coded encashment certificates, and why the bank must ask before turning dollars into Taka.

I-5I-6I-7

In Lesson 26, Online payment gateways and cards for service income, we followed service money along two roads: online payment gateways (OPGSPs) that sweep a freelancer's earnings into a bank's nostro collection account, for service exports of up to USD 10,000 per transaction, and the 'Freelancer Card' for developers of mobile apps and games.

Now Enzo, the young freelance graphic designer from Mirpur, has a new puzzle. Some clients hire him through a big international freelance marketplace, and his money sits in his merchant account there. "Can it come straight to my mobile wallet?" he asks. "My mother pays even the gas bill from her phone these days. I am falling behind my own mother!"

Behind him in the queue at Eliana's export desk stands Tasnim, who runs a small online shop in Rajshahi. She sells handmade nakshi kantha and jute bags to buyers abroad. "A buyer in Canada paid for two kanthas," she says. "Do I really need an EXP form for a parcel worth less than a good phone?"

Eliana has invited a guest to this week's branch session: Ihsaan, a compliance and anti-money-laundering expert who has spent years on KYC and trade-based money laundering. He smiles. "New roads are good roads, as long as we know who is driving and where the money came from. Let's see what the circular allows." This lesson covers international marketplaces and payment operators (I-5), mobile wallets and small e-commerce receipts (I-6), and the customer's choice to keep foreign currency (I-7).

Para I-5

Repatriation of export proceeds through payment service providers

In plain words

I-5 opens a wider door than the OPGSP route in paragraph 3 of this part (Lesson 26). In addition to that route:

  • ADs may allow their service exporter-customers to make arrangements with international marketplaces/platforms, including keeping merchant accounts with them.
  • Service exporters may also keep notional accounts, not only with licensed OPGSPs, but with internationally reputed payment service aggregators, payment facilitators, digital wallets or other legitimate payment systems licensed by their own regulators (eligible foreign payment operators).

When such a platform or operator pays service income into an AD's nostro account, the AD shall facilitate bringing it home, even without an arrangement or a separate nostro collection account. For this, the AD must obtain from the customer:

  1. details of the merchant and/or notional accounts;
  2. a declaration on the nature of the services, with supporting information and documents;
  3. an undertaking to bring the income home within the statutory period, either through the platform or operator, or by credit to the merchant/notional account for immediate transfer to Bangladesh.

Customer due diligence and other regulatory compliance apply.

When the money arrives:

  • The AD credits the Taka equivalent to the customer's bank account, or sends it to a digital wallet with a Mobile Financial Service Provider licensed by Bangladesh Bank. If the customer chooses, the AD first puts money into the ERQ account, up to the permissible limit.
  • If the customer keeps the ERQ account with a different AD, the receiving AD sends the money there in the invoicing currency, through Bangladesh Bank's nostro/clearing accounts. The beneficiary AD does the reporting to Bangladesh Bank.
  • Tax deduction rules apply.

Limits and housekeeping:

  • Currencies: those permitted in paragraph 9, Part-A. Time: the statutory period in paragraph 4, Part-H.
  • Service exporters may operate no accounts abroad for store of value, other than these merchant or notional accounts.
  • If a platform or operator wishes, an AD may keep KYC and AML/CFT compliant foreign currency and non-resident Taka accounts in its name, under the general authorisation, to pay service income by debiting them, following I-5(2).
  • ADs report to Bangladesh Bank with proper codes and follow foreign exchange rules, AML/CFT norms and other laws.

I-5 doesn't state the ERQ permissible limit.

At the desk

Enzo earns USD 600 for a poster through an international freelance marketplace, which pays it into the nostro account of Eliana's bank, though the bank has no arrangement with that marketplace. Eliana already holds Enzo's merchant account details, his declaration that he sells graphic design services (with client e-mails and samples), and his undertaking to bring income home within the statutory period. At his choice, she credits the allowed share to his ERQ account and sends the Taka equivalent of the rest to his mobile wallet. Ihsaan nods. "That file is not a nuisance. It is how we know the poster is real."

Key words
Notional/merchant account
An account that Part-I (paragraphs 3 and 5) lets a service exporter keep, to bring income home through an AD in Bangladesh.
Nostro account
A bank's own account, in foreign currency, held with a bank in another country.
Eligible foreign payment operator
A payment company abroad, such as a payment aggregator, payment facilitator or digital wallet, that is internationally reputed and licensed by its own regulator. Under I-5, service exporters may keep notional accounts with it.
Statutory period
The time limit set by the rules for bringing export money home. For service income, I-5 points to paragraph 4, Part-H.
Read the rule as written (Para I-5)

(1) In addition to paragraph 3 of this part, ADs may allow their service exporter-customers to enter into arrangements, including maintenance of merchant accounts, with international market places/platforms. In addition to such accounts, service exporters may maintain notional accounts, without limiting to licensed OPGSPs, with internationally reputed payment service aggregators, payment facilitators, digital wallets or other legitimate payment systems licensed by the regulatory authorities concerned. Accordingly, ADs shall facilitate repatriation of service income deposited in their nostro accounts by international marketplaces/platforms including eligible foreign payment operators, regardless of having arrangements and maintaining separate nostro collection accounts. In this context, ADs shall obtain-

(a) Detailed information from their service exporter-customers regarding maintenance of merchant accounts with international market places/platforms and/or notional accounts with eligible foreign payment operators;

(b) Declaration on the nature of services to be provided by service exporter-customers with supporting information and documents thereon; and

(c) Undertaking from their customers to the effect that they will arrange repatriation of the service income within statutory period either by way of (i) concerned market places/ platforms or eligible foreign payment operators, or (ii) credit to their merchant/ notional accounts for immediate transfer to Bangladesh. Accordingly, customers' due diligences and other regulatory compliances need to be observed.

(2) While on receipt of inward remittances in nostro accounts on account of service income by way of international market places/platforms or eligible foreign payment operators as per above, ADs shall observe following procedures:

(a) ADs shall credit the receipts in equivalent local currency to respective bank accounts, or arrange to transfer the same to digital wallets maintained with Mobile Financial Service Providers licensed by Bangladesh Bank. At the option of their service exporter-customers, ADs may make the fund available to ERQ accounts up to the permissible limit before transfer the equivalent local currency to respective bank accounts/digital wallets.

(b) In case exporters' ADs are different, at the option of service exporters for maintaining ERQ accounts, ADs repatriating service income shall transfer the repatriated fund through nostro/clearing accounts of Bangladesh Bank to concerned ADs in invoicing currency. For such transfer, beneficiary ADs will follow reporting routine to Bangladesh Bank.

(c) Regulations on deductions of applicable taxes and payment thereof need to be complied with.

(3) Service income is to be repatriated in permissible currencies as per paragraph 9, Part-A and within statutory period as prescribed in paragraph 4, Part-H of this circular. Service exporters can operate no accounts abroad for store of value other than merchant or notional accounts as per above.

(4) At the option of international market places/platforms and eligible foreign payment operators, ADs may maintain KYC and AML/CFT compliant foreign currency accounts and non-resident Taka accounts in their names as per general authorization of foreign exchange regulations for payments on account of service income by debit to the accounts, subject to observance of relevant instructions as noted at paragraph 5(2) of this part.

(5) ADs shall observe reporting routine to Bangladesh Bank with appropriate codification and comply with the relevant foreign exchange regulations, AML/CFT norms and any other relevant laws/regulations in force.

Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part I, paragraph 5 (page 36). The original circular is the authority.

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Para I-6

Repatriation of income from IT related services/small value export proceeds under E-Commerce through MFSPs and PSPs

In plain words

I-6 lets export money come home through mobile wallets. Mobile Financial Service Providers (MFSPs) and Payment Service Providers (PSPs) licensed by Bangladesh Bank may bring home export proceeds, working with internationally recognised OPGSPs, digital wallets and/or aggregators that operate in many countries. The circular calls these partners foreign PSPs.

The MFSP or PSP must:

  • have standing arrangements with the foreign PSPs;
  • keep settlement accounts in equivalent Taka with ADs, under agreements made for this purpose; the foreign PSPs send the money through these ADs;
  • put funds into eligible exporters' digital wallets once the settlement account is credited;
  • keep detailed electronic records, and show them to Bangladesh Bank when asked;
  • inform Payment Systems Department-1 and Foreign Exchange Policy Department-1 at Bangladesh Bank Head Office, through its designated AD, about arrangements with foreign PSPs, and follow Bangladesh Bank's procedures.

The AD:

  • moves the money, on receipt in its nostro account, to the settlement account in equivalent Taka, deducting and paying taxes if applicable;
  • or, as an alternative, may keep accounts in the foreign PSP's name, in foreign currency or Taka, and transfer by debiting them. An overdraft on these accounts is allowed only if the AD holds payment guarantees from banks it accepts, for adequate amounts based on the transaction flows;
  • may keep ERQ accounts for ITES (IT-enabled services) exporters, arranged with the MFSPs and PSPs, up to the permissible limit, credited in foreign currency before the rest goes to the settlement account.

Due diligence covers foreign exchange and payment systems rules, KYC, AML/CFT and other laws.

Encashment certificate: on an electronic request from an MFSP or PSP, backed by auto-generated details (beneficiary's name, wallet account number, Taka amount, date of credit from the remittance service provider abroad), the AD may issue one. After its own screening, it generates an electronic certificate (Appendix-13) with a QR code, reached through the MFSP or PSP. It is for Income Tax purposes only.

Small e-commerce goods: MFSPs and PSPs may also handle proceeds of goods sold through cross-border e-commerce, up to USD 1,000 or equivalent, without the EXP form declaration (the circular points to paragraph 5, Part-J here). Conditions: follow I-6, with nominated ADs acting under I-6(2); do due diligence before onboarding e-commerce exporters; and credit the customer from the settlement account only after receiving the exporter's Bill of Export electronically.

At the desk

Tasnim's buyer in Canada pays USD 85 for two nakshi kanthas through a foreign digital wallet that has a standing arrangement with a Bangladeshi PSP. The money lands in the nostro account of Eliana's bank, which holds that PSP's settlement account, and Eliana moves the Taka equivalent there, after any applicable tax. As the sale is well under USD 1,000, no EXP form declaration is needed, but the PSP credits Tasnim's wallet only after it receives her Bill of Export electronically. At tax time, the PSP asks the bank for an electronic encashment certificate, and Tasnim opens it with its QR code. Ihsaan smiles. "Small parcel, full paper trail. That is exactly how it should be."

Key words
MFSP
Mobile Financial Service Provider: a company licensed by Bangladesh Bank that runs digital wallets people use on their mobile phones.
PSP
Payment Service Provider. Under I-6, a PSP licensed by Bangladesh Bank works with foreign PSPs (online gateways, digital wallets or aggregators abroad) to bring export money into customers' digital wallets.
Settlement account
An account in equivalent Taka that an MFSP or PSP keeps with an AD. Export money from foreign PSPs passes through it on its way to customers' digital wallets.
Encashment certificate
A bank's certificate that foreign currency received was converted into Taka. Under I-6(5), it is issued electronically with a QR code, for Income Tax purposes only.
Read the rule as written (Para I-6)

(1) Mobile Financial Service Providers (MFSPs) and Payment Service Providers (PSPs) licensed by Bangladesh Bank are allowed for repatriation of export proceeds in association with internationally recognized OPGSPs/digital wallets and/or aggregators having operations in multiple countries (hereinafter referred to as foreign payment service providers, PSPs). Accordingly, MFSPs and PSPs shall:

(a) Have standing arrangements with foreign PSPs.

(b) Maintain settlement accounts in equivalent Taka with ADs, under agreements for this particular purpose, through whom repatriation of export proceeds shall be channeled by foreign PSPs.

(c) Make funds available to digital wallets of eligible exporters upon credit of the fund in settlement accounts.

(d) Maintain electronic records of transactions in detail and make them available to Bangladesh Bank as and when required.

(2) ADs shall observe, in connection with operation of the transactions, the following instructions:

(a) ADs shall transfer the fund, on receipt in their nostro accounts, to settlement accounts in equivalent Taka of MFSPs and PSPs. While executing the transfer, ADs shall comply with deduction and payment of taxes, if applicable.

(b) As an alternative to above, ADs may maintain accounts in the name of foreign PSPs at their desire in foreign currency/Taka as per foreign exchange regulations to facilitate the said transfer by debit the accounts. Overdraft facilities may be allowed for the accounts so maintained provided that ADs shall have payment guarantees from banks acceptable to them for the adequate amounts based on the transaction flows.

(c) ADs may maintain ERQ accounts in the name of ITES exporters to be arranged in association with MFSPs and PSPs up to the extent of permissible limit from repatriated proceeds. In this case, ADs shall make funds available to ERQ accounts as per standing arrangement in foreign currency before transfer of the funds to settlement accounts of MFSPs and PSPs.

(3) MFSPs and PSPs entering into arrangements with foreign PSPs shall intimate through their designated ADs to Payment Systems Department-1 and Foreign Exchange Policy Department-1 at Bangladesh Bank, Head office with necessary details. They shall observe admissible procedures to execute transactions in accordance with regulatory instructions issued by Bangladesh Bank from time to time.

(4) Due diligence in respect of the transactions needs to be observed regarding foreign exchange/payment systems regulations, KYC and AML/CFT standards and relevant laws/regulations in force.

(5) ADs maintaining settlement accounts may issue encashment certificates in support of remittances on request from MFSPs and PSPs electronically. In this case, the request needs to be supported by auto-generated information-beneficiary's name, wallet account number, amount in Taka, and date of credit from remittance service provider abroad. Based on their own screening parameters regarding the information, designated ADs shall generate electronic encashment certificate (as per Appendix-13) with QR code accessible to beneficiaries through MFSPs and PSPs. The above-mentioned certificate is intended to be used for Income Tax purposes only.

(6) To further facilitate the smooth receipt of small-value export proceeds against cross border E-Commerce transactions, licensed MFSPs and PSPs may also handle repatriation of export proceeds against export of goods up to USD 1,000 or equivalent without the requirement of declaration on EXP Form as per paragraph 5, Part-J of this circular, subject to the following conditions:

(a) MFSPs and PSPs shall comply with the instructions outlined in paragraph 6 of this part. Nominated ADs shall facilitate the transactions as per the terms of reference set forth at paragraph 6(2) of this part.

(b) MFSPs and PSPs shall conduct due diligence before onboarding E-Commerce exporters.

(c) MFSPs and PSPs shall credit customers' accounts, upon electronic receipt of the Bill of Export from exporters, out of the funds held in settlement accounts maintained with nominated ADs.

Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part I, paragraph 6 (page 37). The original circular is the authority.

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Para I-7

Retention of foreign currency and outward remittance

In plain words

I-7 is short, and it protects the customer's choice.

  • Ask first: before encashing an inward remittance, ADs need to tell individual beneficiaries that they have the option to keep part of it in foreign currency in an ERQ account.
  • No silent conversion: without the customer's consent, an AD should not outright encash the remittance and credit it to a Taka account.
  • Explain the use: ADs should also guide customers on making outward remittances from the retained amount for bona fide current account transactions, as per the relevant ERQ regulations.

Think of a tea stall that asks, "Sugar or no sugar?" before stirring. The bank asks, "Keep some dollars, or all Taka?" before converting. It is a short question, but the answer belongs to the customer.

I-7 itself does not state the ERQ share or list the allowed payments; it points to the relevant ERQ regulations.

At the desk

A USD 500 payment arrives for Enzo late on a Thursday, and a colleague suggests converting it all into Taka to clear the queue. Eliana first messages Enzo about his option to keep part of it in his ERQ account. He says yes, because he pays some business costs abroad. Eliana explains that he can send money out of the retained amount for bona fide current account transactions, under the ERQ regulations, and that the bank will guide him.

Key words
ERQ
Exporters' Retention Quota: the share of export earnings an exporter may keep in foreign currency, in an ERQ account.
Encashment
Converting foreign currency received into Taka.
Current account payment
A payment for everyday trade and services, such as paying for imported goods or a training course. Different from a capital payment, such as buying property or shares abroad.
Read the rule as written (Para I-7)

ADs need to intimate individual beneficiaries regarding their option for retention in foreign currency in ERQ accounts before encashment of inward remittances. Without their consent, ADs should not outrightly encash inward remittances for credit in Taka accounts. ADs should also guide their customers on facilities of outward remittances out of retention amount for bonafide current account transactions as per relevant ERQ regulations.

Source: Bangladesh Bank, FEPD-1 Circular No. 26, 30 July 2026, Part I, paragraph 7 (page 38). The original circular is the authority.

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Putting it together

So far: Beyond the OPGSP route, service exporters may use merchant accounts with international marketplaces and notional accounts with eligible foreign payment operators, and ADs bring that income home into Taka accounts, mobile wallets or ERQ accounts, after taking the customer's details, declaration and undertaking. Licensed MFSPs and PSPs can bring export money into digital wallets through Taka settlement accounts with ADs, including small cross-border e-commerce goods sales of up to USD 1,000 without an EXP form declaration, and ADs may issue QR-coded encashment certificates for income tax use. Through it all, the customer is asked first whether to keep foreign currency in an ERQ account.

Next: Part I of the export room is complete. Part J, on export through e-commerce, starts in Lesson 28, Selling online to shoppers abroad: advance orders and marketplaces.

Check yourself

30 questions, in 3 sets of up to 10. Nobody sees your answers but you.

Set 1 of 3

1. Under I-5(1), with which of these may service exporters keep merchant accounts?
2. Besides licensed OPGSPs, with whom may service exporters keep notional accounts under I-5(1)?
3. Which of these is NOT something the AD must obtain from the service exporter under I-5(1)?
4. Under I-5(3), which paragraph sets the permissible currencies for repatriating service income?
5. Under I-5(3), within what period must service income be repatriated?
6. Under I-5(4), in whose names may ADs keep foreign currency and non-resident Taka accounts to pay service income?
7. True or false: under I-5(1), an AD shall facilitate repatriation of service income paid into its nostro account by an international marketplace, even without an arrangement or separate nostro collection account for that marketplace.
8. True or false: under I-5(2), an AD must credit all service income in Taka and may not put any of it into the customer's ERQ account.
9. Enzo's marketplace payment reaches the nostro account of Eliana's bank, but his ERQ account is with another AD and he wants to keep foreign currency. What must Eliana's bank do?
10. Enzo asks Eliana to send his marketplace income to his mobile wallet instead of his bank account. What does I-5(2)(a) allow?

Set 2 of 3

11. A new customer wants Eliana's bank to bring home his income held with a payment facilitator abroad. Which item should Eliana ask him for under I-5(1)?
12. Enzo jokes, 'I'll leave my earnings in my marketplace account for a few years as savings.' What does I-5 mean for him?
13. In I-6(1), what are 'foreign PSPs'?
14. Under I-6(1)(b), in which currency do MFSPs and PSPs keep their settlement accounts with ADs?
15. Under I-6(2)(b), when may an AD allow an overdraft on an account kept in a foreign PSP's name?
16. Under I-6(3), whom must MFSPs and PSPs inform, through their designated ADs, about arrangements with foreign PSPs?
17. For what purpose is the electronic encashment certificate under I-6(5) intended?
18. Which appendix gives the electronic encashment certificate under I-6(5)?
19. Under I-6(1)(d), what records must MFSPs and PSPs keep?
20. True or false: under I-6(2)(a), an AD transferring funds to an MFSP's or PSP's settlement account must deduct and pay taxes, if applicable.

Set 3 of 3

21. True or false: under I-6(6), MFSPs and PSPs may handle e-commerce goods export proceeds of up to USD 10,000 without an EXP form declaration.
22. Tasnim sells two nakshi kanthas for USD 85 to a buyer in Canada, paid through a licensed PSP's foreign partner. What must the PSP receive before crediting her account?
23. Tasnim receives an order for jute bags worth USD 1,600 and hopes to use the PSP route without an EXP form declaration. What does I-6(6) say?
24. Tasnim's PSP asks the AD electronically for an encashment certificate for her. What must support the request?
25. A licensed PSP plans to sign up small online sellers like Tasnim for the USD 1,000 route. What must it do before onboarding them?
26. Enzo, an ITES exporter, is paid through a mobile wallet arrangement and wants to keep some foreign currency. Under I-6(2)(c), what may Eliana's bank do?
27. Under I-7, what must ADs do before encashing an inward remittance for an individual beneficiary?
28. Under I-7, for what may customers make outward remittances from their retention amount?
29. True or false: under I-7, an AD may outright encash an individual's inward remittance into Taka without the beneficiary's consent, as long as the rate is fair.
30. A USD 500 payment for Enzo arrives late on a Thursday, and a colleague suggests converting it all into Taka now. What should Eliana do under I-7?
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